Bierman v. Target Corporation

CourtDistrict Court, D. Nevada
DecidedSeptember 26, 2025
Docket2:22-cv-01044
StatusUnknown

This text of Bierman v. Target Corporation (Bierman v. Target Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bierman v. Target Corporation, (D. Nev. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 * * *

7 CATHERINE BIERMAN, Case No. 2:22-cv-01044-RFB-NJK

8 Plaintiff, ORDER

9 v.

10 TARGET CORPORATION, 11 Defendant. 12

13 14 Before the Court is the parties’ (ECF No. 39) Stipulation to Seal Documents and (ECF No. 15 40) Emergency Motion to Seal by Defendant Target Corporation. For the following reasons, the 16 Court denies both the Stipulation and Motion. 17 18 I. PROCEDURAL HISTORY 19 The Court recites only the procedural history relevant to the instant Order. 20 On March 16, 2023, the Court entered a stipulated protected order (SPO) between the 21 Parties, governing the disclosure of confidential information in the instant lawsuit. See ECF No. 22 17. The same day, the Court entered an order informing the parties that the approval of the blanket 23 protective order was entered to facilitate discovery exchange, but that “there has been no showing, 24 and the Court has not found, that any specific documents are secret or confidential.” ECF No. 18. 25 The Court further ordered counsel to comply with the requirements of the local rules and the Ninth 26 Circuit’s decision in Kamakana v. City and County of Honolulu, 447 F.3d 1172 (9th Cir. 2006) 27 with respect to any documents filed under seal, and set forth the following procedure for 28 compliance: 1 If the sole ground for a motion to seal is that the opposing party (or non-party) has designated a document as confidential, the designator 2 shall file (within seven days of the filing of the motion to seal) either (1) a declaration establishing sufficient justification for sealing each 3 document at issue or (2) a notice of withdrawal of the designation(s) and consent to unsealing. If neither filing is made, the Court may 4 order the document(s) unsealed without further notice. 5 ECF No. 18 at 1-2. Finally, the Order stated “[t]o the extent any aspect of the stipulated 6 protective order may conflict with this order or Local Rule IA 10-5, that aspect of the stipulated 7 protective order is hereby superseded with this order.” Id. at 2. 8 On October 4, 2023, Plaintiff filed her Opposition to Defendant’s Motion for Summary 9 Judgment under seal, without filing a Motion to Seal, as required by Local Rule IA 10-5(a). See 10 ECF No. 30. On July 25, 2024, the Court ordered Plaintiff’s Opposition unsealed due to her failure 11 to seek leave of Court for the under-seal filing. ECF No. 32. The same day, Defendant filed a 12 Notice to the Court of Plaintiff’s violation of the SPO because of the unsealed Opposition, which 13 contained information designated as confidential by Defendant—namely deposition testimony of 14 Defendant’s Federal Rule of Civil Procedure 30(b)(6) witness which discussed Defendant’s 15 policies and procedures. See ECF No. 33. On July 26, 2024, the Court resealed Plaintiff’s 16 Opposition, based on Defendant’s Notice. ECF No. 34. 17 On September 29, 2024, the Court granted Defendant’s Motion for Summary Judgment 18 and ordered the Parties to stipulate which portions of Plaintiff’s Opposition would remain sealed 19 post-judgement, noting the “strong presumption of public access to court records.” ECF No. 36 at 20 2, n. 1 (citing Folz v. State Farm Mut. Auto Ins. Co., 447 F.3d 112, 1135 (9th Cir. 2003)). 21 On October 14, 2024, Defendant filed a Motion to extend the deadline to file the stipulation 22 regarding redactions as ordered by the Court. ECF No. 37. That Motion attached a proposed 23 stipulation that Defendant had sent to Plaintiff, which included as an exhibit Plaintiff’s Opposition 24 to Summary Judgment with proposed redactions. See ECF No. 37-1. However, Defendant’s 25 counsel inadvertently filed a version of the document in which the stipulated redactions were 26 highlighted, rather than redacted, such that the information was and continues to be visible to the 27 public on the Court’s docket. ECF No. 37. On October 24, 2024, Defendant filed the instant 28 Stipulation, which again attached Plaintiff’s Opposition with proposed redactions highlighted 1 rather than redacted. See ECF No. 39, 39-1. On November 13, 2024, Defendant filed the instant 2 Emergency Motion to Seal, informing the Court of the error and requesting the Court seal 3 Defendants’ unredacted Exhibits. See ECF No. 40. 4 The Courts order on the pending Stipulation and Motion follows. 5 6 II. LEGAL STANDARD 7 In the Ninth Circuit, there is a “strong presumption in favor of access to court records.” 8 Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122, 1134 (9th Cir. 2003). There is a federal 9 common law right of the public “to inspect and copy public records and documents.” Id. The 10 common law right of access, however, is not absolute and can be overridden by sufficiently 11 “compelling reasons” for doing so. Id. Under the “compelling reasons” standard, the party seeking 12 to seal court records “must articulate compelling reasons supported by specific factual findings 13 that outweigh the general history of access and the public policies favoring disclosure, such as the 14 public interest in understanding the judicial process.” Kamakana v. City and Cnty. of Honolulu, 15 447 F.3d 1172, 1178-79 (9th Cir. 2006) (citations and quotation marks omitted). 16 In determining whether records filed in connection with a dispositive motion should be 17 sealed, “the court must conscientiously balance the competing interests of the public and the party 18 who seeks to keep certain judicial records secret.” Id. at 1179 (quoting Foltz, 331 F.3d at 1135). 19 In making the determination, courts should consider all relevant factors, including: “the public 20 interest in understanding the judicial process and whether disclosure of the material could result 21 in improper use of the material for scandalous or libelous purposes or infringement upon trade.” 22 Id. (citing Hagestad v. Tragesser, 49 F.3d 1430, 1434 (9th Cir. 1995). “Under this stringent 23 standard, a court may seal records only when it finds a compelling reason and articulates the factual 24 basis for its ruling, without relying on hypothesis or conjecture.” Ctr. for Auto Safety v. Chrysler 25 Group, LLC, 809 F.3d 1092, 1096–97 (9th Cir. 2016) (citing Kamakana, 447 F.3d at 1178) 26 (emphasis added). 27 In general, “compelling reasons” sufficient to outweigh the public's interest in disclosure 28 include that the records may be used for improper purposes, such as “to gratify private spite, 1 promote public scandal, circulate libelous statements, or release trade secrets.” Kamakana, 447 2 F.3d at 1179 (quoting Nixon v. Warner Commun., Inc., 435 U.S. 589, 598 (1978)). “The mere fact 3 that the production of records may lead to a litigant's embarrassment, incrimination, or exposure 4 to further litigation will not, without more, compel the court to seal its records.” Id. (citing Foltz, 5 331 F.3d at 1136). 6 7 III. DISCUSSION 8 The presumption of public access to court records is strong where, as here, the records 9 sought to be sealed include “motions for summary judgment and related attachments.” Kamakana, 10 447 F.3d at 1179. This principle of disclosure recognizes “the resolution of a dispute on the merits, 11 whether by trail or summary judgment, is at the heart of the interest in ensuring the ‘public’s 12 understanding of the judicial process and of significant public events.’” Id. (quoting Valley Broad. 13 Co. v. U.S. Dist. Ct. for Dist.

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Bierman v. Target Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bierman-v-target-corporation-nvd-2025.